IREG Update June 2019

IREG met on 12th June 2019 and discussed the following MRA Issue Forms (MIFs) and Electricity Central Online Enquiry Service (ECOES) changes.

MIF219 – Full review of the Working Practice Product Set (WPPS)

IREG received an update of the progress of the review. IREG noted the further analysis carried out on the remaining Working Practices and agreed to continue the review. It noted that there were still Working Practices (WPs) that could be removed from the WPPS due to redundancy or included within a review of processes linked to the D0268 Data Flow. As such, it agreed the one (1) drafted Change Proposals (CP) as they were consequential changes to MAP14 since the noted Working Practices had already been withdrawn and could progress to MDB.

MIF278 – Gap with HH Change of Meter Operator

IREG reviewed the current position of the MIF noting some comments had been received previously from the Meter Operators via the RFI agreeing that the Manufacturers Make and Type should be made Mandatory in line with the D0150 and D0303 Data Flows, however there were very low volumes that actually were issued without the Manufacturer Make and Type being completed.

IREG highlighted that any future changes would need to cognisant of the move to the CSS for switching and IREG agreed for this MIF to be closed and be incorporated within a new D0268 specific MIF that was in train.

MIF281 – Crossed Meters

IREG noted the draft procedure developed had been shared with the ECOES Technical Service Provider to develop an outline ECOES solution for the procedure. The high-level outline of deliverables was provided to the group for their initial comments. The group noted a workshop would take place to refine the ECOES solution. IREG noted that once the outline solution is understood then other work will be required in developing the Change Proposal and the case for change.

MIF285 – Review of the Valid Set codes under the J1253 and use of the J0024 to better describe a change of energisation status rejection

The Proposer updated IREG on their considerations to the responses received back from the RFI which was issued in February regarding the options to fix the issue raised. The Proposer noted that original processes set up and codes used within the J1253 were in the main from a Meter Operator point of view and there were scenarios’ where a Distribution Business could not advise on the correct reason for the Energisation rejection because there were insufficient codes to select and hence raising the MIF. A member highlighted that a previous MIF, 100 had been raised which was very similar but rejected. The Proposer noted that they felt from the responses there were still issues in this area. The Proposer advised that their preference was for option 1 and amend the Logical Format for the J1253 Data Item to CHAR2 as if the change was approved the consequential changes could be made for the additional scenarios identified. IREG discussed the best approach to take the solution forward and agreed that option 1 was the correct solution therefore would be better to raise a Change Proposal rather than going through an SPF. The Proposer agreed that they would take that forward and raise the CP.

MIF288 – Industry Contacts Database

IREG reviewed the high-level Impact Assessment carried out by the website Technical Service Provider. IREG noted that that a few the requirements discussed at the last meeting could be developed, however, the bulk update requirement would require significant effort due to the data security and trying to minimise loss of data and quality when opening a spreadsheet. The TSP felt that the same result could be delivered through creating a proper database and being able then to set people up and then could select the roles those people would be undertaking. IREG agreed to the proposals and recommended a request is made to MRASCo Board to release funds to enable the developments to be completed.

MIF290 – Licence Exempt Network Indicator

IREG were advised that the Indicator was a requirement for the Ofgem Switching Programme although not a need for the introduction of the CSS. There had been a joint BSC/MRA Working Group which had initial discussions on what the solutions could be, however, further work had been suspended due to Ofgem carrying out an internal review first. This review had been completed and the outcome issued within the paper pack. Similarly, within the papers there was an update from the AMO to why Meter Operators would find it helpful to have this Indicator in place too and whether the two requirements could be addressed through the Ofgem needs may need reviewing.

IREG highlighted that there were a few questions which needed driving out before a solution could be agreed. How to identify the Private Network, what the processes are which are in place to create and manage a Private Network and what issues have the MOps in managing their or their customer assets on the network.

IREG advised that where a customer who was on the Private Network wanted to take advantage of selecting their own Supplier, they would apply for an MPAN from the DNO and then select a Supplier via the switching services. IREG noted that potentially a Supplier may not need the flag if the customer has the MPAN and switch via MPAS, but the MOp may need to know if managing the meter that sat on the network.

IREG noted that the processes for interacting with a Private Network primarily sit outside of the MRA mainly in the BSC for impacts on Settlements and DCUSA for charging and where the MPAS obligations land in the future. IREG recommended that a new Cross Code Working Group was set up including BSC, DCUSA and MRA representation to explore how a solution could be developed and to update Ofgem on the discussions.

MIF292 – Lower Case Meter Serial Numbers

The Chair presented the MIF and reminded IREG that the issue had been identified by FSEG whereby MPRS will be processing the D0312 and D0304 Data Flows under the new arrangements from the June 2019 release and that the data received within those Data Flows will be converted and stored in uppercase and any subsequent response data within the Data Flows are sent out in uppercase. The issue was believed to impact Meter Operators (MOps) and Supplier systems if they are expecting the MSN back in lowercase. IREG were advised that within ECOES there were approximately 2000 MSN records, current and historic that are in lowercase.

IREG noted that at the May meeting they had suggested that a note was added to the ECOES URS as that would be a more cost-effective option as the numbers in that situation was likely to reduce over time going forward. IREG reviewed the drafted note set out in the papers and a member advised that a purer solution would be to add the note to the J0004 (Meter Id (Serial Number) Data Item within the Data Transfer Catalogue as the physical serial numbers were in lower case and thus the Meter Operator would have a clear rule to which they should adhere. A member agreed to raise a Change Proposal to add a note that when sending the J0004 (Meter Id (Serial Number) Data Item it should be in Uppercase. IREG agreed to close the MIF.

MIF296 – Review of Non-Domestic Customer Access to ECOES

The Proposer advised that this had been raised following the recent review of the standard ECOES Access processes and that this process had not been incorporated within that review. There were some known issues within the process such as when a Supplier approves an NDC access to view an MPAN there was no process to review the access meaning an NDC could keep their access to the MPAN after a COT had occurred. In some cases, access had been given to a consultant or TPI and their access could not be removed at the end of the customer contract. Similarly, just need to ensure that the process is now GDPR compliant. IREG agreed that the review of the end to end process should be taking place and ironing out any deficiencies within it to make it compliant.

MIF297 – Use of the D0304 Data Flow from MOp to Supplier in a New Connection Scenario

IREG highlighted that these processes were all set out in the BSC in that the D0304 was only sent on a change of MAP and outcome fed back to the Proposer.

The Proposer advised that this issue since the Impact Assessment of MAP CP 0312 it was identified that there was no designated process within MAP21 on how both Distributors and Suppliers should progress a bulk update in respect of logical disconnections. It is possible that with the current data cleansing activity that the industry is currently undertaking this could result in a significant increase in the number of logical disconnection requests going forward and as such a process requires to be put in place to manage this. The Proposer highlighted the solution could be adding wording into MAP21 such that it was expected that a bulk update will consist of at least 50 or more logical disconnection requests at any one time – this number is based on the bulk update threshold that was introduced as part of the additional MPAN request process in ECOES. It is expected that the initiating Supplier will contact the relevant Distributor and bi-laterally agree a solution based on the overall number of requests that the Supplier wishes to logically disconnect. IREG agreed that the wording could cover off the Bulk updates for Logical Disconnections. The Proposer agreed to close the MIF and draft a Change Proposal ready for July19 MDB.

IREG noted that the process went live in the February 2019 release and MDB had agreed for a post implementation review to take place in June 2019. IREG were advised that there was a link between the review and delivery of the solution agreed under MIF283 (ECOES Upload to Distribution Third Party Systems) as any changes would need changes to the output files too.

IREG were advised that the process seemed to be received well although some feedback had been received on some areas as to how when the Supplier raises a request for an MPAN creation, they select the DNO MPID from a drop-down list at times they were incorrectly assigned and the fact that a Party could not take any further action until a response was received. IREG agreed these should be investigated as to whether these are as set out in the specifications. IREG advised that filtering of requests and users along with option to download the reports were already within the system.

IREG agreed that the solution for MIF283 (ECOES Upload to Distribution Third Party Systems) could now been progressed through the ECOES TSP. Their preference being within the November 2019 Release.

Safeguarding Customer Working Group

IREG received a verbal update from the previous Safeguarding Customer Working Group (SGCWG) highlighting that that testing plans are in development to test water sector DTN. IREG noted that MPAN address mapping to the water sector was being explored and recommendations following last month’s IREG regarding the ECOES API, which could be utilised, but exploring their own options currently. IREG noted that some of the DNOs will be looking to issue test D0225s where they have consent to hold and pass customer information on. IREG were advised that these obligations were introduced some time ago through a combination of Water UK, Ofgem, Ofwat obligations and commence next year.